Ampyx Cyber Blog
The Intersection of Regulation & Resilience
NERC CIP Audit Readiness: A Strategic Compliance Guide 2026
Stop treating NERC CIP audits as fire drills. Learn the proactive timelines, documentation discipline, and live audit approach that separate prepared utilities from panicked ones. Here’s a strategic guide to compliance sanity from a former CIP auditor.
Computational Load and the Convergence Problem: What NERC's May 2026 Actions Mean for Critical Infrastructure
Documented load losses approaching one thousand megawatts in seconds. A Level 3 Essential Action Alert. A final Reliability Guideline. Proposed registration of a new Computational Load Entity. NERC's May 2026 actions mark a structural shift in how data centers, hyperscale AI training, and cryptocurrency mining are treated under the North American grid reliability framework.
Funded, Not Secured: The April 20 DPA Determinations & the Bulk Electric System
Two April 20 Defense Production Act determinations expand domestic capacity for grid components and large-scale energy infrastructure. Neither addresses cybersecurity. For the electric sector, NERC CIP and Order 693 standards still apply. A practitioner's view of intersections with CIP-013, CIP-014, PRC, FAC, and TPL, and why domestic capacity is not domestic assurance.
Cyber-Informed Transmission Planning: Seven Pilots, CIP Leverage
NERC's April 2026 release of the Cyber-Informed Transmission Planning lessons learned captures seven 2024 pilots. None triggered a corrective action plan. The report's most consequential finding: strengthening low-impact CIP requirements is likely a more cost-effective leverage point than expanding TPL-001 to embed coordinated cyber contingencies.
CIP-003 Low Impact Vendor Remote Access: Expert Audit Questions
A deep dive into NERC’s Currently Compliant Podcast Episode 8, extracting every key question being asked about CIP-003-9 vendor remote access. These questions provide a clear view into audit expectations across the ERO Enterprise and highlight where entities are struggling with visibility, control validation, and monitoring of vendor access.
FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do
FERC unanimously approved Order Nos. 918 and 919 on March 19, 2026, finalizing CIP virtualization standards and new low-impact BES Cyber System controls, plus an updated "Control Center" definition. All CIP-registered entities are affected. Implementation windows are 24 and 36 months respectively. Compliance programs should begin gap assessments now.
NERC’s CIP Roadmap and the Future of Grid Cybersecurity
NERC’s new CIP Roadmap signals a major shift in how cyber risk will be regulated across the power grid. This Policy Pulse explains what NERC released, why it matters, what standards and guidance are coming next, and how utilities, generators, and grid operators should prepare for expanding CIP scope and enforcement.
ERO CMEP 2026: Oversight in the Age of Transformation
The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.
INSM Just Got Clearer: Key Takeaways from the NATF Guidance
NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.
Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management
FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.
Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains
FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.
CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope
FERC Order 907-A clarifies CIP-015 on shared networks. INSM must monitor only east-west traffic used for access monitoring of EACMS and PACS. Non-CIP assets and data flows are out of scope, even in mixed-use or commingled PACS/EACMS environments. Learn practical patterns to filter collection, segment analytics, and produce audit-ready evidence.
2025 RISC Report: Cybersecurity at the Center of Grid Reliability
The NERC 2025 RISC Report elevates cybersecurity to the core of grid reliability, alongside grid transformation, extreme events, interdependencies, and volatile energy policy. Unlike past reviews, this report is a forward-looking roadmap, urging modernization, cross-sector coordination, and resilience in a digitized, high-risk energy landscape.
CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.
CIP-015-1 INSM: A Practical Playbook
NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.
Monitoring Meets Mandate: Will the Next CIP-015 Standard Deliver on FERC’s Vision?
FERC approved CIP-015-1, but also ordered NERC to expand it. The new SAR outlines how INSM requirements will extend beyond the ESP to include EACMS and PACS systems. This post breaks down how the SAR aligns with FERC’s directive, what still needs attention, and why internal visibility is no longer optional.
Help Shape the Future of the NERC CIP Standards
NERC is asking for industry input on the future of CIP Standards. As part of its 2025 Work Plan, NERC has launched a survey to identify and prioritize emerging security risks to the Bulk Power System. The results will directly inform a roadmap for updating the CIP Standards to address today’s evolving threat landscape. What’s happening, why it matters, and how you can participate before the July 22 deadline.
FERC Quietly Closes The Books on RM20-12-000
FERC has officially closed Docket RM20-12-000, ending a five-year inquiry into potential gaps in the CIP Reliability Standards. While the docket is withdrawn, the underlying concerns—data security, anomaly detection, and coordinated cyberattacks—are being addressed through recent standards like CIP-015-1 (INSM) and proposed updates to CIP-003.
FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid
On June 26, the Federal Energy Regulatory Commission issued Order No. 907, approving the new NERC Reliability Standard CIP-015-1: Cyber Security – Internal Network Security Monitoring (INSM). This marks a critical shift in how we approach cybersecurity within the Bulk Electric System. It also raises the bar significantly on what’s expected for visibility inside the network perimeter.
NERC CIP-002 Standards Authorization Request - Project 2021-03
NERC’s CIP-002 Project 2021-03 (Phase 2) introduces key updates to improve clarity and consistency in identifying and classifying BES Cyber Systems. The revisions address long-standing ambiguities by clarifying functional entity roles, refining the treatment of communication protocol converters, revising Criterion 1.3 to establish objective criteria for high-impact control centers, and expanding Criterion 2.6 to include control centers operated by Generator Operators and Transmission Owners. These changes aim to eliminate gaps in protection, align risk-based categorizations across all entities, and support more consistent compliance with CIP standards.